Electrical safety - testing and tagging regulations

The new WHS legislation has added to the confusion surrounding testing and tagging - one of the key elements of electrical safety. In this article, Sarah Allen from Appliance Tagging Services explains the revised testing and tagging requirements across Australia.

Much has been talked about with the introduction of the new WHS legislation in Australia. Designed to reduce the complexity of businesses operating across state borders, the model WHS legislation is, in theory, a no-brainer. As it stands, New South Wales, Queensland, Australian Capital Territory and Northern Territory are the only states to have adopted the new WHS regulations. Most other states are opting to implement in 2013, South Australia is undecided and Victoria has chosen not to implement them at all citing the implementation costs business would face if introduced in that state.

The much needed removal of complexity is still a long way off, and the area of electrical safety legislation is just as confusing as ever. But, don’t be fooled - even if all states did eventually adopt the model WHS regulations, there would still be state-specific differences.

Safe Work Australia has attempted to clear up some of the confusion surrounding testing and tagging. The regulations state all appliances located in a hostile operating environment must be inspected, tested and tagged regularly by a competent person and a record maintained of the testing. All items not located in these environments should be subject to a documented risk assessment, which may in fact recommend the testing and tagging of the appliance.

A hostile environment is one that is exposed to heat, dust, moisture, corrosion, abrasion or vibration. For example, poorly designed work stations with leads on the floor, training rooms, kitchens, tea rooms and manufacturing environments. There are specific codes of practice for the construction industry which also specify mandatory testing and tagging of portable electrical appliances.

With regards to RCD safety switch testing, the new WHS regulations state that all circuits operating in a hostile environment must be protected by an RCD. That RCD must then be tested regularly in accordance with the Australian Standard, AS/NZS 3760:2010. The AS/NZS 3760:2010 In-Service Safety Inspection and Testing of Electrical Equipment specifies the safety inspection and maintenance standards for Australia and New Zealand. It is vital to remember that the Standard should be read in conjunction with both national and state-specific legislation as testing and retesting requirements detailed in legislation will vary from state to state.

In Victoria, the OH&S Act 2004 specifies that, “An employer so far as reasonably practicable, provide and maintain for employees a working environment that is safe and without risk to health.” The Victorian Electrical Safety Act 1998 also states that all second-hand equipment being made available for sale must be inspected, tested and tagged prior to sale. Similar electrical safety legislation also exists in Western Australia, Tasmania and in South Australia where the testing of RCDs in accordance with AS/NZS 3760 is detailed. WA and Tasmania will adopt the National WHS regulations in 2013, while Victoria will not, and South Australian implementation is in doubt.

Even with the introduction of the National WHS regulations in Queensland, the legislation surrounding testing and tagging is covered by the Electrical Safety Act 2002 and the amendment issued in 2006. This detailed legislation is based on six ‘Classes of Work’ and dictates the retest frequencies associated with the testing of appliances within each class of work. The six classes of work are categorised as: Construction Work, Manufacturing Work, Office Work, Service Work, Amusement Work and Rural Industry Work. The legislation also specifies the requirements of RCD installation and testing under AS/NZS 3760, along with requirements surrounding double adaptors and piggy back plugs for different classes of work.

In addition, it is also a requirement under the Queensland Electrical Safety Act for a test and tag service provider to be deemed competent and hold a Restricted Electrical Contractors licence.

Who is responsible for testing and tagging?

The AS/NZS 3760:2010 makes specific references to the responsibilities of ‘the responsible person’ to ensure the competency of technicians undertaking a test and tag program. The responsible person is the owner of the premises, equipment or, under new WHS regulations, is the PCBU or Officer deemed to be responsible for the safety of the workplace.

One of the most important areas of competency is the understanding of the Standard. All ‘responsible persons’ should ensure their test and tag providers own a copy of the current AS/NZS 3760 and understand its contents, and not just the retest frequencies. It is also worth checking that the test and tag provider holds both Public Liability and Professional Indemnity insurances.

Information on tag

An addition has been made to assist workplaces in easily identifying when their appliances are due for retesting. The AS/NZS 3760:2010 now specifies that the retest date must be added to the durable, non-reusable, nonmetallic tag placed on the item after testing. This is in addition to the requirement for technician/company name, test or inspection date, and whether the item passed or failed testing.

“New to Service”

In New Zealand, all new items must be tested and tagged before they are introduced to service. In Australia, there is a requirement for all new items being introduced to service to be tagged with a New to Service tag. The tag must state the item is “New to Service”, it must state the date of entry to service, the date it will be tested and that “This appliance has not been tested in accordance with AS/NZS 3760”.

Leased equipment

In some workplaces, leased appliances such as vending machines, water coolers, computers, photocopiers and the like have not been included in a test and tag program as they have been incorrectly thought of as ‘exempt’ or the responsibility of the lessor. The AS/NZS 3760:2010 now specifically states that the hiree or the lessee is responsible for the inspection, testing and tagging of hired and leased equipment while the equipment is in their possession.

Electric shock

Many people have been using a ‘one size fits all’ approach to testing and tagging. For example, the equipment used in a workshop of a manufacturing facility should be tested on a six-monthly basis, and a number of unscrupulous test and tag providers have been known to test the entire facility on a six-monthly basis. Some businesses believe testing and tagging is simply an oncost and not a program that has saved, and will continue to save, lives.

It’s important to remember that even in a non-construction environment, up to 10% of appliances fail first-round testing and all of those appliances have the potential to kill. Electricity is not visible and most people have an ‘it won’t happen to me’ attitude when it comes to electric shock. Providing a safe workplace is mandatory, regardless of attitudes and misconceptions about electricity, and the sometimes blatant disregard of the seriousness of an electric shock.